Mastering Transfer Pricing Litigation: A Strategic Imperative for Multinational Enterprises
With audits increasing 79% in intensity and number (EY 2023), transfer pricing litigation has never been more urgent—or more costly. In fact, 40–5…
Tag: MNEs
2025 Transfer Pricing Postgraduate Programmes: A Strategic Investment for MNEs and Revenue Authorities
With global tax landscapes continually evolving, comprehensive training is no longer optional—it is essential.
The Transfer Pricing Postgraduate Pr…
Treatment of Tax Transparent Entities Under Pillar Two: Implications for Multinationals and Revenue Authorities
The implementation of Pillar Two represents a paradigm shift in global tax governance. A cornerstone issue that demands careful scrutiny within this t…
India vs AON Consulting: TRANSFER PRICING CASE
The High Court of Delhi, in its ruling on AON Consulting Pvt. Ltd. v. Principal Commissioner of Income Tax – 1 and Ors. (ITA 244/2024), addressed a …
Kenya vs Avic International: TRANSFER PRICING CASE
The Tax Appeals Tribunal in Kenya ruled on the case involving AVIC International Beijing (EA) Limited (Appellant) and the Commissioner of Domestic Tax…
Kenya Revenue Authority’s Guidance on Mutual Agreement Procedure: A Comprehensive Analysis
The Mutual Agreement Procedure, commonly referred to as MAP, is a dispute resolution mechanism that enables contracting states under a DTA to resolve …
F Taxpayer vs SARS: Procedural Compliance in Tax Disputes
In the matter of F Taxpayer v SARS, the Tax Court of South Africa was tasked with evaluating the procedural compliance and statutory adherence of the …
Australia vs SingTel Transfer Pricing Case
The High Court of Australia deliberated on a significant transfer pricing case between Singapore Telecom Australia Investments Pty Ltd (STAI) and the …
EU State Aid in Transfer Pricing and its International Relevance
State Aid, an important concept within the European Union's (EU) legal framework, serves to prevent competitive imbalances by prohibiting member state…
A Comparative Analysis of Anti-Avoidance Measures in Cross-Border Transactions
In international tax law, striking the right balance between anti-avoidance measures and cross-border economic freedoms is an ongoing challenge. Europ…